2025 (3) TMI 1609

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....entral Circle-2, Bhubaneswar to Central Circle-1, Bhubaneswar. 2. The Petitioner pleaded that he is a Fish Commission Merchant and doing business. While so, search and seizure under Section 132 and survey operations under Section 133A of the Act were conducted at various locations of M/s. Falcon Marine Private Ltd., and others, who were engaged in shrimp sale, manufacturing of Iron and Steel, mining and excavation of Iron Ore and Manganese etc., at Odisha, Chhattisgarh, West Bengal and Andhra Pradesh on 01.06.2023. Pursuant to the aforesaid search, the Petitioner's case was also brought under Section 132 of the Act. On 04.07.2023 summons were issued under Section 131(1A) of the Act, wherein the Petitioner was called upon to produce books....

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.... i.e. Odisha, Chattisgarh, West Bengal and Andhra Pradesh. In the course of search operations, the Petitioner had business and financial transactions with M/s. Falcon Marine Private Ltd., and others. It was stated that certain incriminating material was found during the search operations under Section 132 of the Act between M/s. Falcon Marine Private Ltd., and the Petitioner, which were marked as HO-18 and HO-19. 6. It was also pleaded that during the course of simultaneous search under Section 132 of the Act against Petitioner and his father Sri D. Pitchaiah, certain digital data was seized and was marked as A-BVSH-BMV-RES-69. Further plea was that there was suppression of purchases of Rs. 9,33,97,666/- by the petitioner for the Financi....

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....on of the counsel for the Petitioner was that the impugned order was passed without giving the Petitioner a reasonable opportunity of being heard and after recording reasons. 11. The Standing Counsel appearing for the Respondents contended that the impugned order was a conscious decision taken by the Respondent No.1 following the Central Board of Direct Taxes Circular and pursuant to that decision, the investigation was centralized to DCIT, Bhubaneswar and a number of cases were transferred to the said office. It was further contended that no special treatment can be given to the Petitioner. 12. This Court having seen the impugned order is of the opinion that since a number of cases were transferred to DCIT, Bhubaneswar regarding inve....